2024 Self-Audit Series #6: Return to Stock
PAAS National® analysts continue to see pharmacies face recoupment on audits due to return to stock violations. Pharmacies argue the patient received the medication, so how can the claim be recouped? Unfortunately, each PBM contract has a specific number of days, within which, the pharmacy must dispense the medication. Dispensing outside this time frame will likely result in full recoupment of the claim if discovered upon audit.
PBM return to stock windows range from 10 – 30 calendar days. With no industry standard interval, PAAS recommends …
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PAAS FWA/HIPAA members can review and update their current policy, located in Section 4.1.1 Unclaimed Prescriptions, in their policy and procedure manual. Additionally, members have access to an Unclaimed Prescription Reversal Log, that can be found in Appendix B.
PAAS Tips:
- Review your current Return to Stock policy and procedures to ensure compliance with 10 calendar days
- Prioritize time for an assigned employee to complete this task
- Run daily reports identifying prescriptions not picked up according to your policy; this should include completions of partially filled prescriptions due to medication out of stock issues
- Regularly monitor oversized bins, special order areas, and refrigerators
- Watch for out-of-stock prescriptions, claims should be billed when product is available
- Contact your pharmacy management and/or point of sale system to see if they can program to stop sales of prescriptions that exceed your policy
- This would allow the claim to be reprocessed with an updated fill date which would reset the return to stock timeline
- LTC claims are not exempt from return to stock windows; the clock starts from the date billed, not the date physically filled
- Beware of REMS prescriptions having specific restrictions for pick up, see our June 2021 Newsline article, Would Your REMS Prescription Pass an Audit?
- Reverse and rebill any prescriptions the patient intends on picking up soon or asks you to “hold”
- Do not have patients sign for prescriptions that were previously received, this does not provide accurate dating during audit review and can hurt your appeal options
Don’t have written compliance policy and procedures? Consider joining the PAAS National® FWA/HIPAA Compliance Program today! info@paasnational.com or (608) 873-1342.
I attended Madison College in nearby Madison, WI (PAAS headquarters are in the Madison suburb of Stoughton). Prior to coming to work at PAAS, I worked as a Certified Pharmacy Technician in a retail setting for 25+ years. Pharmacy has been my life’s work.
Helping our members have a successful audit experience is very rewarding. Celebrating with them, when PAAS often helps generate positive post-audit results, is the best part of my work.
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